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Police Criminal Complaint: Commonwealth of Pennsylvania vs. Elise Ballard (Dauphin County)

Summary

A police criminal complaint, Commonwealth of Pennsylvania vs. Elise J Ballard, in Dauphin County, with an affidavit sworn by Agent Chris Weaver and Agent Katie Grady. The affidavit describes Pandemic Unemployment Assistance (PUA), created by Section 2102 of the CARES Act, and notes that inmates are listed as ineligible to receive PUA in Pennsylvania. It states that the Department of Corrections identified possible PUA fraud involving inmates at SCI Rockview and other state correctional institutions, and identified Elise J. Ballard through prison inmate messages. According to the affidavit, Ballard said in an interview that Ballard filed PUA applications for inmates, withdrew the money from the debit cards received and transferred it to inmate prison accounts.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

                                                                               ffi
  COMMONWEALTH OF PENNSYLVAN IA                                                                         POLICE CRIMINAL COMPLAINT
  COUNTY OF:DAUPHIN                                                                                      COMMONWEALTH OF PENNSYLVANIA
  Magisterial District Number: L2-2-04                                                                                                  VS.
  MDJ: Hon. Sonya M, McKnight                                                  DEFENDANT:                                      (NAME and ADDRESS/:
  Address: 1805 North Cameron St.                                              ELISE                                 J                        BALLARD
              Harrisburg, PA L7L03                                             First Name                            Middle   Name            Last Name                           Ge
                                                                                                                                                                                  n
                                                                               718 Linden Avenue, Johnstown, PA 15902
  Telephone : (7 L7)233-3599
                                                                          NclG Extradition Code rvpe-
  lal 1-Ferony Fuil                                l_l S-Felony Pending Extradition                              -
                                                                                             E C-nlisOemeinor SurrounOing States                      E Distance:_
  E 2-felony Limited                               n 6-Fetony Pending Extradition Determ.        E O-Uisdemeanor No Extradition
  fl 3-Fetony Surrounding States                   E R-tvtisOemeanor Fuil                        E e-UisOemeanor Pending Extradition
  [ +-Felony No Extradition                        E e-[4isOemeanor Limited                      I F-Misdemeanor Pending Extradition
  Docket Number                               Date Filed            OTiflLiveScan Number                   ComplainUlncident Number                  Request Lab

   U- IJ'LI
  GENDER
                                              I iat Al     frlil76b-3                                       occ-70-0075
                                                                                                                                                     Services?
                                                                                                                                                          fl ves Ex ruo
                         DoB L2/0L/LgB7             PoB Pennsylvania                                    Add't DoB I              I                   Co-Defendant(s) tr
  E nnae                          First Name                                       Middle Name                                Last Name                                     Gen.

  El Female             AKA

 ,RACE                  E wnite                             Asian                            ( Black             J Native American                   tr Unknown
  EI   HNIUIIY ll Hispanic               X Non-Hispanic                                     tr Ur,L"o*r
          E cnv (Gray) E neo (Red/Aubn.)       E sov (sandy)                                E aLu (etue) ! er-e (purpte)                             f] eno (Brown)
 E:i:, EX elr (Brack) E oNc (oranse)                                 flwntwhite)            E xxx (unk./Batd) E cnru (Green)                         E prur (pinr<)
              E SLt'l (Btonde / Strawberry)
 Eye
 Color
              E elx (Btack)
              D unz (Hazet)
                                           E elu (erue)      E eno (Brown)
                                           f] nlten (Maroon) ft prur (pinx)
                                                                                                    LIcRN (Green)
                                                                                                    E uut- (Multicotored)
                                                                                                                                               ffi
                                                                                                                                               E xxx (Unknown)
 DNA                           I tr vrs EI No I oxa Location                                                                                           i WEIGHT (lbs.)
 FBI Number
                                                                    MNU Number
                                                                                                                                                         235
 Defendant Fin gerprinted              fl Yes E ruo                                                                                                      Ft, HEIGHT ln.



                                                                                                                                        ry
 Fingerpri nt Glassification :
                                                                                                                                                          5           9
                                                                     DEFENDANT VEHIGLE INFORMATION
                                      Stal re-rHatl                Registration              Comm'lVeh.              School Veh.                                           Reg.
 Plate #                                       lmatl                                             lnd. tr                    tr
                                               lnl           Sticker (MM/YY) I
                                                                     Make
                                                                                                                                               -                       same
                                                                                                                                                                       re Flaf
 VIN                                                       Year                             lruoaetffi                                               Color                 tr
 Office of the attorney for the Commonwealth I Approved tr Disapproved because:


 to filing. See Pa.R.Crim.P. 507).

 HEATHER A. CASTELLINO, SDAG
                                                                                                                                                          / I lsl 2-oz I
                                                                                                                                                                  (Date)


                  CH
       (Name of the Affiant)                                                                          (PSP/MPOETC -Assigned Affiant tD Number & Badge #

            Pennsvlvania                                                                                 PAA2224}O
    (ldentify Department or Agency neprese                                                            (Police Agency ORI Number)
    do hereby state: (check appropriate box)
 1- E I accuse the above named defendant who lives at the address set forth above
        fl I accuse the defendant whose name is unknown to me but who is described as
        E I accuse the defendant whose name and popular designation or nickname are unknown to me and whom I have
      therefore desiqnated as John Doe or Jane Doe
     with violating the penal laws ot the commonwealth of Pennsylvania at
                                     Pa                                                                [301]
                                                                                            pA Dept Of Labor And Industry,
 6513oas St, Harrisburg,                                                  (-suEeivEi6Fsoiref-                                        tnaffi
          in DAUPHIN County                          t22t                     on or about JUNE LL,2020 TO SEPTEMBER L,2020


AOPC 4I,2A- Rev. TlLS                                                                                                                                            Page 1 of        -6
                                                                                                               ,ffi poLtcE cRIMINAL coMpLAtNT
  DdA":,i?!"!,t                             Date Filed:                      OTN/LiveScan Number                                      ComplainUlncident Number
                                                tt                                                                                    occ-20-0025
                                       First:                                   Middle:                                       Last:
  Defendant Name:
                                       ELISE                                    J                                             BALLARD


  Theactscommittedbytheaccusedaredescribedbetow
  When there is more than one offense, each offense should be numbered chronolo!ically.
  (Stt forth a brietsummary of the lacts suf{icient to advbe the doiendant ot the naturo of tlre offense(sichargld. A cltation to the statute(!} allegedly vlolatod,
  without more' ls notsuffclont In a summ€ry case, ylu must c1!.lhe speciflc sectlon(s) and sub6ection(s) oithe statuts(s) or ordinanceisi atteieat! vblataa.
  The age of tho victim at the time ot lho offense may bo included if known. ln addltlon, social security numLers and finaniiil inlormaton          pli{s} ihgutu not
                                                                                                                                             1e.9.
  be list d. lf the ldontity of an account muat be establstred, tist onty tho tast four dtgi&. 204 pA.cod;
                                                                                                           SS 213,1 - 21g.7.]




    tr        1
              Offense
                            911                      b3 Y                       rrrLElB                         1              F1
  Lead?                           uectron                Subsection                                                                         NCIC Offense
                  #                                                                 PA Statute (Title)             Counts
                                                                                                                                               Gode
                                                                                                                                                                UCR/NIBRS Code

                                                                                                          E lnterstate I               f Safety Zone              E Work Zone
 statute Description (include the name of statute or orolnance)r' conRupr oRGANrzATroNs

 ActsoftheaccusedaSSociatedwiththisoffense:TheDefendantdid,beingemptoyeauyo.iffi
 2020 and september of 2020, within the counu€s of Dauphin, Huntingdon, centre, cambria, Pennsylvania and els€where, mnduct or participate, directy or
 indirecty in the conduct of such enterprise's affairs through a pattern of racketeering activity, that                  i;
                                                                                                        during the periods is set forth herein. Defendant was
 associated with an enterprise mnstih.ting a group of individuals associated in fact aithough not a teiat entity, engag€d in commerce and consisting
                                                                                                                                                       of Robert
 Palmer, John R. Jones, and others, and Defendant did conduct or partjcipate, directy or inOireaty, iritne conauct-ofihe affairs of the enterprise thiough
                                                                                                                                                           a
 pattern of racketeering actrVity as defined in 18 Pa.C.S.
                                                           5911(h) mnsisting            of
                                                                                   (See Attached Offense Continuation)




  n       2                 911                      b    4            }1t##l rrrlE 18                         1              F1
 Lead?                                                                                                          counts                      NClc offense
                                                     Subsection                     PA Statute (Title)                           Grade         Code             UCR/NIBRS Code

                                                                                                          E Interstate                 I Safety zone             E Work Zone
 StatuteDescription(includethenameofstatuteorIoNs
 ActsoftheaccusedassociatedwiththiSoffense:TheDefendantdid,didbetweenJuneof2ozo"no!ffi
 Dauphin, Huntingdon, centre, Cambria, Pennsylvania and elsewhere, conspired to violate the provisions of Section 9i1(b)(3) of the irimes Code, 18 pa.C.S.
 5911(b)(3), pertaining to coffupt OrganizauonE that is, during the periods as set forth herein, Defendan! wtth the inteni of promoting or facilitating the
 commission of the crime of conupt organizationt did conspire and agree with other individuals, that they, or one or more oi hem, wiile employed-by or
 associated with the enterprise set forth herein, would condud or participate, djrectly or indirectly, in the aonduct of the affaiE of the enterprise througfr a
 pattem of racketeering adivity as defined in 18 Pa.C.S. q911(h), in violation of Section 911(bX4) of the Crimes Code, 18 pa.C.S.
                                                                                                                                       S911(b)ti).



                                                 E soticitation            I Conspiracy                             Number of Victims Age 60 or Older
                                                     18 902 A                18903

   n          3              392L                        a               affi'r TITLE 18                       31               F2
                        #               )n                Subsection                             I rfle            Counts           irade   NCIC Offense Codr     UC
                      Data
                                                                                                           I lnterstate                 fl Safety zone            E Work Zone
Statute Description (include the name of statute or ordinanCe). rrlrFr By uNLAwFUL TAKTNG oR DrsposrrroN


Acts of the accused associated with this Offense: The oefendang took or exercised unlawtul controt orer. mova6ielroffiii anomer,-ii6-iif
intent to deprive him thereof. The Defendant committed the offense during a Natural Dlsaster involving a catastrophe which results in iubstantial damage to
property, hardship, suffering or possible loss of life.




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                                                                                                     ffi poltcE cRtMtNAL coMpLArNT
  'ff:"i?o:ir                      Date Filed:
                                          lt
                                                                    OTN/LiveScan Number                                     Com plainUlncident Number
                                                                                                                            occ-20-0025
                                 First:                                 Middle:                                   Last:
                                 ELISE                                  J                                         BALLARD




                                                                            PA Statute   itle            Counts           ]rade                     Coda    I leR/NlFl

                                                                                                 E lnterstate I                   fl Safety zone I          n Work Zone
  StatuteDescription(includethenameofstatuteoi

 Actsoftheaccusedassociatedwiththisoffense:meoe
 Theft By Unlawful Tahng Or Disposition, litle 18 Section 3921(a), did agree with one or more other persons that they or one or more
                                                                                                                                        of them would engage in
 condud which constitutes a ffime or did- agree_to aid such othar person or persons in the planning oi commisiion of iucir crime or of an attempt
                                                                                                                                                   or solic-ita'tion
 to commit such sime, that iE between June of 2020 and september of 2020, within the (iunties-of Dauphin, Huntingdon, Centre, Cambria, pennsylvania
                                                                                                                                                              and
 elsewhere, Defendant did agree with other individuals that they, or one or more of them, rvould engage in condua co;Etuting thi
                                                                                                                                     oime oi tnen oi, untawrut
 takinq in-violauon of l'itle 18, and in pursuance of such conspiracy one or more overt acts were mmmitted, in violation of Section
                                                                                                                                    903 of the crimei Code, 18
 Pa.C.S. 6qm.




               5         3szz lus                           YiW,ffirrrLElB                            31             F3




                                                                El conspiracy                         Number of Victims Age 60 or Older
                                                                   18 903

  u        6            3922                   a3          '**:iil,;ril TITLE 18                    31             F3
               fense#                                                                                Counts          )rade           NCIC Offense   Code   UCR/N|BRS Code

                                                                                                fl Interstate        |            tr Safety Zone I         n Work Zone
 Statute Description (include the name of statute or orOlnancey: cnrMrNAL coNsprRAcy

Acrs oT Ine accuseo assoclated with this Offense: The Defendant did, with the intent of promoting or tucititaung the commission of tre crinre of
Theft By Deception, title 18, section 3922(aX3), did agree with one or more other persons that they or one o-r more of them would engage
                                                                                                                                               in conduct which
constitutes a crime or did agree to aid such other person or persons in the planning or commission of such crime or of an attempt
                                                                                                                                  or solicjtation to commit
such crime, that is, between lune of 2020 and S€ptember of 2020, within the counties of Dauphin, Huntingdon, crnre,
                                                                                                                        Ombrii, pennsytvania and elsewhere,
Defendant did agree with other individuals that they, or one or more of them, would engage in .oriOua constit,itin! me crime or
                                                                                                                                uret u! aecepuon, in violation
of lite 18, and in pursuance of such conspiracy one or more overt acts were committed, in violation of Section 90i of the oimes code,'l8 pa:C.S,
                                                                                                                                                      !903.




AoPfi{rA - Ril ?/rir -                                                                                                                                         Pagei of I S
                                                                                                                ffi poLtcE cRIMINAL coMpLAtNT
  -lff;13; Al
  Docket Number:                        Date Filed:
                                               tt
                                                                              OTN/LiveScan Number                                            Com plainUlncident Number
                                                                                                                                             occ-20-0025
                                      First:                                       Middle:                                       Last:
                                      ELISE                                        J                                             BALLARD




                                                                                                             f] lnterstate                      fl Safety zone            E Work Zone
 Statute Description (include the name of statute or ordinance): REcErvrNG sroLEN pRopERTy

 Acts of the accused associated with this Offense: The Defendan! intentionally rec€ived, retained or disposed of movable property of another
 knowing that it had been stolen or believing that it has probably been stolen, unless the property is received, retained, or disposed with intent to restore it to
 the owner.




                     E Attempt                      fl Solicitation         I Conspiracy                            I UumUer of Victims Age 60 or Older
                           18 901 A                    18 902 A                18903                                I




    tr
  Lead?
               B
               Offense#
                            75L2
                                    Section
                                                        aSubsectionf,ffi,ffirrrlE               18
                                                                                        PA Statute   Irfle
                                                                                                                    1
                                                                                                                        Counts
                                                                                                                                    F3
                                                                                                                                         )rade
                                                                                                                                         c          NCIC Offense   Code    UCR/NIBRS Code

                                                                                                              n lnterstat" |                    [ safety zone I           n work Zone
 Statute Description (include the name of statute or ordinance): cRTMTNAL usE oF A coMMUNrcATroN FAcruw

 Acts of the accused associated with this Offense: The Defendant did, on or about the above menuoned date and time use a communication facility
 to commit, cause or facilitate the commission or the aftempt thereof of any crime under this title or under the PA Controlled Substance, Drug, Device and
 Cosmetic Act 64-1972, all of which is in violation ofthe IUe 18 PA CS 57512.




                   fl Auempt                    D soticitation            I Conspiracy                              ruumber of Victims Age 60 or Older
                          18901 A                    18 902 A                18903                              |
   tr      9                4/ 0G                     a1    iii       I ortrre I   fnlf rA                      1                 F3
 Lead?                                                 Subsection                      PA Statute                   Counts          Grade          NCIC Offense   Code    UCR/NIBRS Code

                                                                                                             E lnterstate |                    tr Safety Zone |           tr Work Zone
Statute Description (include the name of statute or ordinance): AccEss DEvrcE FRAUD

Acts of the accused associated with this Offense: The Defendant did on or about the above mentioned date, tjme and location, uses an access
device to obtain or in an attempt to obtain property or services with knowledge that the access devic€ has been revoked or canceled.




AOPC 4L2A - Rev. T lLg                                                                                                                                                        Page   Lof F
  Docket Number:                   Date Filed:
                                                                                                             ffi poLtcE cRtMtNAL coMpLAtNT
                                                                           OTN/LiveScan Number                                     Com plainUlncident Number
     ct- i3- 2/                           lt                                                                                       occ-20-0025
                                 First:                                       Middle:                                      Last.
                                 ELISE                                       J                                             BALLARD




                                                                                   PA Statute      Irue           Counts                     NCIC Offense Code     IICR/NIBRS Code

                                                                                                           n lnterstate I              n Safety Zone I            n Work Zone
 Statute Description (include the name of statute or ordinance): e,ccEss DEvrcE FRAUD

 Acts of the accused associated with this Offense: The defendant did on or about the above mentioneo oatejime and location, publishes, mates,
 sellt gives, or otherwise transfers to another, or offers or advertises, or aids and abets any other pe6on to use an access device knowing that the access
 device is counterfeit, altered or incomplete, belongs to another person who has not authorized its i.rse, has been revoked or canceled or f6r any reason is
 unauthorized by the issuer or the device holder.




   tr       11         4106                    a   3        |r''lg{ji:.   ,, TtrLE 18                        1              F3
  Lead? Offense#                               Subsection                        PA Statute     I ItI€           Counts       )rade        NGIC Offense Code      UCR/NIBRS Corla

                                                                                                          fl lnterstate I              n   Safety   Zone I        n Work Zone
 Statute Description (include the name of statute or ordinancel: nccEss DEvrcE FRAUD


 Acts of the accused associated with this Offense: The defendant did on or about the above mentionea oat", ti,iiano tocatior,,J*Gran
 access device knowing that it is counterfei! altered, incomplete or belongs to another person who has not authorized its possession.




                                                                                 PA Statute                      Counts        Grade        NCIC Offense   Gode   UCR/NIBRS Code

                                                                                                          E lnterstate |               tr Safety Zone I           I Work Zone
statute Description (include the name of statute or ordinance): TAMPERTNG wrTH puBlrc REcoRDs oR r FoRMATrOrra

Acts o, the accused associated with this Offense: The Defendant, knov\,ingly makes a false enuy in, or False alteration of, any record, document or
thing belonging to, or received or kept by, the govemment for information or record, or required by law to be kept by others for information of the
government.




AOPC 4L2A- Rev. TlrS                                                                                                                                                 Page   J of /5
 Docket Number:                  Date Filed:                      OTN/LiveScan Number
                                                                                                  ffi poLtcE cRtMtNAL coMpLAtNT
                                                                                                                         Gom plai nUlncident Number
     cr- l.E- 1l                        lt                                                                               occ-20-0025
                               First:                                 Middle:                                    Last:
 Defendant Name:
                               ELISE                                  J                                          BALLARD




                                                                                       I tlte


                                                                                                E lnterstate I              n Safety Zone            E Work Zone
 Statute Description (include the name of statute or ordinance): uNswoRN FALsrFrcATroN To AUTHoRrrrEs


 Acts of the accused associated with this Offense: The Defendant did, with intent to mislead a public servant in performing his official function,
 made a written false statement which the defendant does not believe to be true.




   tr       L4       I 5111                    a2                                                   1               F1
  Lead?                                          ubsection                 PA Statute (Title)           Counts                  NCIC Offense

                                                                                                 E lnterstate I              n Safety Zone I         n Work Zone
Statute Description (include the name of statute or ordinance): DEALTNc rN pRocEEDs oF UNLAWFUT AcrrvrrrEs


Acts of the accused associated with this Offense: The Defendant did on or about tlre above mentioned date, Ume and location conducls a financial
tansaction under any of the following circumstances with knowledge that the property involved, including stolen or illegally obtained properfy, represents trle
proceeds of unlaMul activity and that the hansaction was designed in whole or in part to conceal or disguise the natrre, location, source, ownership or control
of the proceeds of unlat/vful actjvity.




                 I Attempt               fl solicitation      E Gonspiracy                          Number of Victims Age 60 or Older
                    18901 A                  18 902 A             18 903


                                                       I ortrre ]
 Lead? Offense#             Section           Subsection                  PA Statute   itle         Counts           )rade     NCIC Offense   Code   UGR/NIBRS Code

                                                                                                fl lnterstate I            tr Safety Zone I          n work Zone
Statute Description (include the name of statute or ordinance):


Acts of the accused associated with this Offense:




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                                                                ffi poLtcE cRtMtNAL coMpLAtNT
                                                                               OFFENSE GONTINUATION PAGE
 Docket Number:          Date Filed:                                                Com plainUlncident Number
  et ' ii:2t
                                                OTN/LiveScan Number
                           tt                                                       occ-20-0025
                       First:                      Middle:                  Last:
                       ELISE                       J                        BALLARD


                                OFFENSE DESCRIPTION CONTINUATION

 Offense # 1:

 A.     Multiple acts of Criminal Conspiracy to commit violations of the Chapter 39 of the Pennsylvania Crimes
 Code, 18 Pa.C.S.A. 5903,

 B.       Multiple acts of violation of the Chapter 49 of the Pennsylvania Crimes Code, including 18 Pa, C.S. A.
 s4911,

 C.     Multiple acts of violation of Chapter 39 of the Pennsylvania Crimes Code, including 18 Pa. C.S.A. 5 3921
 and 18 Pa. C.S.A. 5 3922;

 in violation of Section 911(bX3) of the Crimes Code, 18 pa.C.S. S911(bX3).




AOPC 4L2A- Rev. 07 lI.8                                                                                   Page   I ot l-g
                                                                                   ,ffi poltcE cRIMINAL coMpLAtNT
  Docket Nuruiber:             Date Filed:                OTN/LiveScan Number                         Com plainUlncident Number
    Cr'l s- 2,/              First:
                                      lt                                                              occ-20-0025
                                                             Middle:                          Last:
                             ELISE                           J                                BALLARD

     2. I ask that a warrant of anest or a summons be issued and that the defendant be required to answer the charges I have
       made.

     3. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and
        belief. This verification is made subject to the penalties of Section 4904 of the Crinies Code fi8 pa.C.S. S 4904) retating
        to unsworn falsification to authorities.

     4. This complaint consists of the preceding page(s) numbered 1 through
                                                                                       -..f
     5. I certify that this filing complies wlth the provisions of the Case Records Pubtic Access Policy of the unified Judiciat
        System of Pennsylvanta that require filing confidential information and documents differently that non-confidential
       information and documents.

    The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth
    oJ Pennsylvania and were contrary to the Act(s) of the Assembly, or in violation of the statutls i:jted.
    (Before a warrant of arrest can be issued, an affidavit of probable cause muat be completed, sworn to before the
    issuing authority, and attached.)



                                                 (Year)                                                       (Signatu
    (Date)

    AND NOW, on this date                                              I certify that the complaint has been properly completed and verified.

    An affidavit of probable cause must be completed before a warrant can be issued.



             '' 2-c /
    (Magisterial District Court Number)




AOPC 4L2A - Rev. Tltg                                                                                                               Pase   Lof Js
                            Date Filed:          OTN/LiveScan Number
                                                                     ffi polrcE cRtMtNAL coMpLAtNT
                                                                                    ComplainUlncident Number
   U:'YTITI                      tt                                                 occ-20-0025
                        First:                      Middle:                 Last:
                        ELISE                       J                       BALLARD



                                          AFFIDAVIT of PROBABLE CAUSE
   OnMarch27,2020,the CARES Act was signed into law, which included Title II, Subtitle A, "Relief for Workers
   Affected by Coronavirus Act." Section 2102 of the CARES Act oeated a temporary federal program called
   Pandemic Unemployrnent Assistance (PUA) that in general provides up to 39 weeks of unemployment benefits
   and provides funding to the slates for administration of the program. The PUA program provides unemployment

   assistance to individuals not eligible for regular unemployment compensation (UC) or extended benefits under

   state or Federal law, including those who have exhausted all rights to such benefits. While the U.S. Deparhent of

  Labor (USDOL) oversees the Pandemic Unemployment Assistance (PUA) program, the Pennsylvania Departnnent
  of Labor & Industry administers the program in Pennsylvania.


  PUA is only for individuals who are unemployed due to COVID-l9 reasons and does not cover individuals
  without an attachment to the labor market or those who are unemployed for non-COVID- 19 reasons. This benefit
  is only for individuals who would otherwise be working but are unable to because of the current pandemic.
  According to the Pennsylvania Deparhnent of Labor & Industry's website, the following $oups are explicitly
  defined as being ineligible to receive PUA: lrmates; Retirees with no job and no job offer; Individuals who were
  not working at all or did not have a job offer; Children who were not working in actual employment; Individuals
  being paid to file other people's PUA application; College Students with no job and no job offer; lndividuals on
  Social Security Disability with no work attachment; Claimants who work as an employee and qualifu under
  regular Unemployment Compensation; Individuals living in a halfuay house on lock-down; and Landlords.
  Additionally, the Pennsylvania Deparbrent of Labor & Industry's website states that "Knowingly making false
  statements or omitting material facts to obtain PUA benefits to which you are not entitled will result in a
  disqualification and repayment of all overpaid PUA benefits. You may also be subject to criminal
  prosecution." On June I,2020, T}lie Pa. Office of Attomey General received a referral letter from the Govemor's
  office referring investigation and prosecution of PUA related fraud based upon the findings ofan audit conducted
  by the Pa. Dept. oflabor & Industry.


  In June of 2020 the Deparhnent of Correction identified possible PUA fraud involving inmates at SCI Rockview
  and oiher state correctional institutions. The Deparhnent of Corrections identified Elise J. Ballard through prison
  inmate messages as possibly being part of the PUA fraud. The Department of Corrections identified messages
  between SCI Rockview inmate John Jones and Elise Ballard where 10 inmate names, DOB's, and SSN,s were
  being provided.


AOPC 41rC   - Rev. OT ILS                                                                                      Page9 of   l5
                            Date Filed:          OTN/LiveScan Number
                                                                     # polrcE cRTMTNAL coMpLArNT
                                                                                    ComplainUlncident Num ber
  'EF*-*;I2"2t                   lt                                                 occ-20 -oo25
                          First:                    Middle:                 Last:
                          ELISE                     J                       BALLARD



 The Department of Conections identified that Elise Ballard was also connected tfuough prison messages and
 prison account payments with SCI Huntingdon inmate Robert E. palmer.


 Your affiant was aware of a pattern of recent fraud scheme from previous PUA fraud investigations that imates
 were contacting individuals outside of the prison using the State Correctional lnstitution communication system
 and providing them with names, DOB's, and SSN's of inmates and having the person on the outside Iile for pUA.

 Since the inmates were incarcerated, the person on the outside needed to complete the pUA application and also
have an address for the PUA funds to be sent. Affiant also leamed from
                                                                           i:revious investigations involving pUA
fraud, that the payments would be sent to tle inmate at the address provided on the application in the form ofa US
Bank Debit card and on some occasion's actual checks from the PA Treasury. Once the pUA flrnds were received
money would be placed on the inmate's prison financial account "JPay" by the person receiving the funds and the
person who submitted the application if different from the person who received the funds would receive
                                                                                                                       a
payment. JPay is the name of the intemal prison money transfer service to deposit money on inmate's commissary

or trust account.



On 8/27120, Affiant haveled to Johnstown, PA and made contacr with Elise Ballard at her residence 718 Linden
Avenue, Johnstown, PA.


Ballard was home and agreed to talk in her living room. Ballard was advised that she was being contacted
regarding inmates obtaining unemployment and asked if she was in possession of any unemplognent debit cards.
Ballard stated that she did have debit cards aad was involved in filing for PUA unemployrnent for inmates. During
tlis conversation Ballard was sitting at a desk with a functioning desktop computer. Ballard reached into the desk
drawer and handed your Affiant a US Bank Debit card in the name of Atbert Williams, an inmate at SCI
Huntingdon. Ballard stated that she had received approximately five, US Bank Debit cards at her address and used
them all and either threw them away or misplaced them. Ballard ageed to go to the Johnstown police Departrnent
to sit down aad discuss her role in the PUA unemployment fraud. Ballard drove herself to the Johnstown police
Department to be interviewed.



AOPC 4LZA- Rev. T   lts                                                                                         Page lo of   [5
  Docket Number:          Date Filed:            OTN/LiveScan Number
                                                                    ffi poLrcE cRTMTNAL coMpLArNT
                                                                                    ComplainUlncident Number
  k-/3-At               First:
                                 tt                                                 occ-20-0025
                                                    Middle:                 Last:
                        ELISE                       J                       BALI.ARD

 Elise Ballard was read her Miranda wamings and agreed to answer questions and make a statement. The interview
was also recorded. Ballard stated that she had a boyfriend, two brothers, and several good friends in state
correctional facilities. Ballard stated that Robert Palmer is her boyfriend and is in SCI Huntingdon; John Jones is
her best friend in SCI Rockview. Ballard stated that she had been asked by Palmer and Jones to file unemployrnent
applications for them. Ballard stated that she understood that filing the applications was not allowed and was
fraud. Ballard stated that she thought the pandemic (PUA) money was available to anyone who applied and
considered it like stimulus money tlat everyone could get. Batlard stated that she filled out numerous applications
for numerous inmates and could not reca1l how many applications she completed. Ballard could not recall how
much money she received from the debit cards. Ballard stated that she put rnost of the money on inmate accounts
through the prison JPay accounts and sent lmger amounts to inmates through MoneyGram. Ballard was shown her
communications with inmates and admitted that she had exchanged the messages and inforrnation for other
inmates during conversations with inmates. Ballard stated that she only had five of the debit cards mailed to her
address in inmate names and the rest of the applications she completed were sent to each inmate's residence.
Ballmd stated that She did not receive any payment ftom the other inmates for filling out the applications. Ballard
was questioned about the other inrnate's names and stated several times that she could not recall the numbers and
amounts involved with the debit cards. Ballard stated that there were '1oo many to remember". Ballard reported
that she lived alone at the 718 Linden Avenue address. Ba.llard reported that her home intemet was through
Atlantic Broadband and that the account was in her name or in Robert Palmer,s name.


Your Affiant's reviewed the Department of Corrections inmate financial JPay accounts for inmates John Jones and
Robert Palmer. Elise Ballard was listed on the JPay accounts as putting $3680.00 on John Jones and $2205.00 on
Robert Palmer's inmate accounts in June, July and August of 2020. The deposits into the inmate accounts
coincided with the PUA payments placed on the debit cards for those inrnates. The JPay system identifies the
name and the IP of the person making the deposit and the IP associated with the majority of the deposits made by

Elise Ballard came from IP address 138.207.247.124.


Upon reviewing prison messages between Elise Ballard and her boyfriend Robert Palmer, an additional 20 names
with DOB and SSN's were found. It was determined that inmate Robert Palmer provided 20 inmate names along



AOPC 412A - Rev. 7 lLg                                                                                         Paoe/l of lS
                                                                                                                 Jr-
  Docket Number:r         Date Filed:            OTN/LiveScan Number
                                                                    ffi poLrcE cRTMTNAL coMpLArNT
                                                                                    Com plainUlncident Num ber
   Lf - /3-11                  lt                                                   occ-20-0025
                        First:                      Middle:                 Last:
                        ELISE                      J                        BALLARD

 with DOB's, and SSN's to Elise Ballard tlrough prison messages. The 20 names provided by Palmer to Ballard
 coincide with completed PUA applications submitted by Ballard.


 Your Affiant's requested additional information from the PA Departrnent of Labor and Industry, specific to Elise
Ballard. Labor and Industry was able to search for the names ofthe inmates associated with Ballard, applications
completed with similar IP addresses associated with Ballard, and for addresses associated with Ballard. The
Departrnent of Labor and Industry found 42 names associated with the search criteria related to Elise Ballard; 31
ofthe PUA applications were completed using IP address 138.207 .247.124. Your AfEant conducted a search and
determined that IP address 138.207.247.124 is owned by Atlantic Broadband. A search of Atlantic Broadband
records determined that IP address 138.207 .247 .124 belonged to subscriber Robert Palmer at 718 Linden Avenue,
Johnstown, PA.


As a result of the semch by the Department of Labor and Industry, the names provided by inmates John Jones and
Robert Palmer, were identified as having PUA applications completed. Additional names who had PUA
applications completed were found associated with Elise Ballard. The total for all the PUA applications completed
by Elise Ballard was 31 applications. 20 of the names were provided by Robert Palmer and 10 of the.names were
provided by John Jones. Not all applications that were submitted by Ballard were approved for PUA payments.
One name SCI Huntingdon inmate Albert Williams could not be determined how Ballard received. it. Albert
Williams was the name on the debit card in the possession of Elise Ballard on 8/27120. Checks with SCI
Huntingdon determined that Albert Williams was the cellmate of Robert Palmer at SCI Huntingdon from April of
2020 rxlJLil September of 2020. The total PUA funds associated with the 3 I PUA applications completed by Ballard
was $226,082.00.



The Pennsylvania Office of Attomey General contacted the Pennsylvania Departrnent of Labor and Industry and
requested the application and paynent information regmding Robert E. Palmer and John R. Jones PUA claims.



The Perursylvania Department of Labor and Industry records show that Robert Palmer had an application for pUA
submitted on June   ll, 2020. On the application it was reported that Palmer's last day of employment was
12/112019. Your Affrant notes that Palmer was incarcerated on the date his application was submitted.

AOPC 4I,2A- Rev. TlLS                                                                                            Page lLot   !;
                                                                      # poLtcE 6RIM;NAL coMpLArNT
    Cr' /3 - ll
  Docket Number:            Date Filed:            OTN/LiveScan Number                 ComplainUlncident Number

                          First:
                                 lt                                                    occ-20-0025
                                                      Middle:                  Last:
                          ELISE                       J                       BALLARD

 Additionally, records show that Palmer's application was submitted by an individual using the address 718 Linden
 Ave, Johnstown, PA. Pennsylvania State Correctional Institution records show that Robert palmer has been
 incarcerated in SCI Hunlingdon from l1ll/16 thru present.


 The Peru:sylvania Deparhnent of Labor and Industry also provided information regarding pUA payrnents made to
 Robert E. Palmer. Records show that Palmer received payments on 6112120 (check), 6117120 (debit card),6/20120
 (debit card), 6/23/20 (debit card), 6129120 (debit cafi), 719/20 (debit card), and,7l|5t20 (debit card). The
                                                                                                                  totat for
 all the pat, nents was $15,660.00. The payrnents were from the last day of work listed on palmer,s application to
present. These palments directly coincide with the time that Palmer waS incarcerated at SCI Huntingdon.
                                                                                                                      The
PUA paynents were made using check and a US Bank pre-paid debit card with the last four numbers 0310. The
Pennsylvania Departrnent of Labor and Industry records show that Palmer's PUA US Bank debit card was
                                                                                                                   mailed
to the Linden Ave, Johnstowq PA address.


The SCI Huntingdon inmate money accor.mt "JPay" showed that Palmer received money on his account from Elise
Ballard on 6113/20, 6116120, 6119120, 6123/20, 6/27120,7121/20,7130120,8t3t20, and B/3U20. T\e total amounr
deposited, on Robert Palmer's JPay account by Elise Ballard was $2205.00.



The total amount of PUA firnds that were associated with the 20 names Robert Palmer provided Ballard through
the State Correctional Institution communication system and the PUA funds he received was $163,907.00.


The Pennsylvania Department of Labor and lndustry records show that John R. Jones had an application for pUA
submitted on June 12,2020. On the application it was reported that Jones last day of employment wa s 12129/2019.
Your Affant notes that Jones was incarcerated on the date his application was submitted. Additionally, records
show that Jones application was submitted by an individual using the address 718 Linden Ave, Johnstown, pA.
Pennsylvania State Correctional Institution records show that John R. Jones has been incarcerated in SCI
Rockview from 2/7/17 tluu present.


The Pennsylvania Department of Labor and Industry also provided information regarding the payments
                                                                                                              made to
Jones. Records show that Jones received payments on 6/13/20 (check), 6/23/20 (debit card), 6129120 (debit
                                                                                                                   cxd),

AOPC 4L2A- Rev.    tlts                                                                                           ;il;E"f 5
                                Date Filed:       OTN/LiveScan Number
                                                                      # polrcE cRTMTNAL coMpLArNT
                                                                                      Com plainUlncident Number
  "tri"lYH"-"2/                        tt                                             occ-20 -0025
                              First:                 Middle:                  Last:
                              ELISE                  J                        BALLARD

 and 7/15D0 (debit card). The total for all the payments was $21,630.00. T\e payments were from the last day of

 work listed on Jones application to present. These payrnents dfuectly coincide with the time that Jones was
incarcerated at SCI Rockview. The PUA payments were made using check and a US Bank pre-paid debit card with
the last four numbers 1629. The Pennsylvania Departrnent of Labor and lndustry records show that Palmer's PUA
US Bank debit card was mailed to the 718 Linden Ave, Johnstown, PA address.


The SCI Rockview inmate money account "JPay" showed that Palmer received money on his account from Elise
Ballard on 6123/20, 6126/20, 6127/20,717/20, ard 7/25120. The total amount deposited, on Robert Palmer's JPay
account by Elise Ballard was $3680.00.


The total amount of PUA firnds that were associated with the l0 names John Jones provided Ballard through the
State Correctional Institution communication system and the PUA fimds he received was $83,545.00.



On 1l/17120, your AfEants traveled to Johnstown, PA and conducted a second interview of Elise Ballard at 718
Linden Ave., Johnstown, PA.


Ballard was read her Miranda warnings and agreed to answer questions and make a statement. The interview was
also recorded.



Ballard.was questioned about the additional names and applications reported by the Deparhnent of Labor and
Indusry. Ballard admitted to completing all the applications from the list of31 PUA applications. Ballard stated
that she personally received 24 of the PUA US Bank debit cards that were sent to Johnstown addresses. Ballard
stated that she used her address and friends addresses in Johnstown to get the debit cards. Ballard stated that the

debit cards mailed to other cities were sent to the individual inmate's families and she had no further involvement.
Ballard was asked what she did with all the debit cards she received. Ballard stated that once she received a debit
card she would withdraw the money and transfer the money to inmate prison accounts. Ballard stated that she
disposed of several ofthe debit cards and some still had balances on the cards. Ballard stated that she knew what
she was doing was wrong and regretted completing the applications. Ballard stated that she was 'Just trying to help

people out".

AOPC 412A      - Rev. 7 lrB                                                                                       Page   ltof /5
                                                                         & poLtcE cRtMtNAL coMpLArNT
  'rFyyj"zt          r --
                              Date Filed:
                                     tt
                                                        OTN/LiveScan Number           Com plainUlncident Number
                                                                                      occ-20-oo25
                            First:                        Middle:             Last:
  Defendant Name:
                            ELISE                         J                   BALLARD




I, AGENT CHRIS WEAVER/AGENT KATIE GRADY, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE
AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND GORRECT TO THE
BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF.

I CERTIFY THAT THIS FILING COMPLIES WITH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS
POLICY OF THE UNIFIED JUDICIAL SYSTE/W OF PEA"VSYLVANIA INAT REQUINC FILING CONFIDENTIAL
INFORMATION AND DOCUMENTS DIFFERENTLY THAT NON.CONFIDENTIAL INFORMATION AND DOCUMENTS.




Sworn to me and subscribed be
                                                                                                    2o2/
                    Date


My commission expires first Mon             January,
                                                       2O;4



AOPC 4I,2A- Rev. TlLS                                                                                             page6 or/5


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